Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Regarding additions u/s 14A for disallowance of expenditure related to exempt income, the ITAT upheld the CIT(A)'s order, which modified the Assessing Officer's (AO) disallowance by excluding investments not yielding exempt income, in accordance with the law. The ITAT rejected the assessee's claim for accepting its suo moto disallowance. On the issue of short credit of TDS, the ITAT directed the AO to grant relief expeditiously as per the CIT(A)'s directions. Concerning short credit of Dividend Distribution Tax (DDT), the ITAT dismissed the ground, stating that the matter requires administrative resolution between the assessee and the Revenue authorities. Regarding denial of foreign tax credit u/s 90/91, the ITAT directed the AO to consider the assessee's case and pass a suitable order. On the allowability of ESOP compensation as revenue expenditure, the ITAT upheld the CIT(A)'s order, following the coordinate bench's decision in the assessee's own case for earlier years.
Regarding additions u/s 14A for disallowance of expenditure related to exempt income, the ITAT upheld the CIT(A)'s order, which modified the Assessing Officer's (AO) disallowance by excluding investments not yielding exempt income, in accordance with the law. The ITAT rejected the assessee's claim for accepting its suo moto disallowance. On the issue of short credit of TDS, the ITAT directed the AO to grant relief expeditiously as per the CIT(A)'s directions. Concerning short credit of Dividend Distribution Tax (DDT), the ITAT dismissed the ground, stating that the matter requires administrative resolution between the assessee and the Revenue authorities. Regarding denial of foreign tax credit u/s 90/91, the ITAT directed the AO to consider the assessee's case and pass a suitable order. On the allowability of ESOP compensation as revenue expenditure, the ITAT upheld the CIT(A)'s order, following the coordinate bench's decision in the assessee's own case for earlier years.
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